Scott v. Brown, 6:21-cv-00071

Three pretrial detainees at Bulloch County Jail (Scott, Baillie, Mayhew) submitted a single, 38‑page pro se complaint raising § 1983 claims about medical care and jail conditions.
Each plaintiff’s pages described different, individual claims: Scott (hernia care), Baillie (Crohn’s disease care), Mayhew (hygiene, access to courts, disciplinary issues).
All pages were docketed together against multiple jail officials; only Baillie filed a motion to proceed in forma pauperis (IFP).
The magistrate applied Eleventh Circuit PLRA precedent holding multi‑prisoner IFP suits are improper because § 1915(b) requires each prisoner proceeding IFP to pay the full filing fee.
Court concluded the combined filing circumvents the PLRA and recommended dismissal without prejudice under Hubbard, but permitted re‑filing individually.
Recommendation: clerk open three new cases (one per plaintiff, same filing dates); docket Baillie’s IFP in his new case; each plaintiff has 21 days to file an individual complaint and, if desired, an IFP motion (Scott and Mayhew must file theirs).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether multiple prisoners may proceed jointly IFP under the PLRA	Plaintiffs sought to proceed together and Baillie asserted inability to obtain account records to pay fees	PLRA (28 U.S.C. § 1915) and Eleventh Circuit precedent prohibit multi‑plaintiff IFP suits; each prisoner must pay full fee or file separately	Multi‑plaintiff IFP suits not permitted; court recommends dismissal without prejudice and directing separate cases
Appropriate procedural remedy for a combined pro se prisoner filing	Plaintiffs implicitly ask court to accept the combined filing as filed	Defendants (and precedent) favor dismissal/severance to enforce individual fee/payment requirements	Case should be dismissed without prejudice and clerk ordered to open three separate cases with same filing dates
Treatment of an individual IFP motion filed within a combined submission	Baillie filed an IFP motion and seeks to proceed IFP	Other plaintiffs did not file IFP motions; PLRA requires each prisoner to seek IFP individually	Clerk ordered to file Baillie’s IFP in his new case; Scott and Mayhew must file IFP motions within 21 days

Hubbard v. Haley, 262 F.3d 1194 (11th Cir. 2001) (PLRA requires each prisoner proceeding IFP to pay full filing fee; multi‑plaintiff IFP suits may be dismissed)
Anderson v. Singletary, 111 F.3d 801 (11th Cir. 1997) (Congress intended PLRA to curb abusive prisoner litigation)
Gandy v. Bryson, [citation="799 F. App'x 790"] (11th Cir. 2020) (reaffirming Hubbard’s application to prisoner IFP proceedings)